HomeMy WebLinkAbout1780 HutchesonPHONE: 717-783-1610
TOLL FREE: 1-800-932-0936
In Re: Matthew Hutcheson,
File Docket: 19-033
FACSIMILE: 717-787-0806
WEBSITE: wwmethics.Damov
Respondent X-ref- Order No. 1780
Date Decided: 3/29/21
Date Mailed. 4/l/21
Before: Nicholas A. Colafella, Chair
Mark R. Corrigan, Vice Chair
Roger Nick
Melanie DePalma
Michael A. Schwartz
Shelley Y. Simms
This is a final adjudication of the State Ethics Commission.
Procedurally, the Investigative Division of the State Ethics Commission conducted an
investigation regarding possible violation(s) of the Public Official and Employee Ethics Act
("Ethics Act"), 65 Pa. C. S. § 11.01 et seq., by the above -named Respondent. At the commencement
of its investigation, the Investigative Division served upon Respondent written notice of the
specific allegations. Upon completion of its investigation, the Investigative Division issued and
served upon Respondent a Findings Report identified as an "Investigative Complaint," An Answer
was filed, and a hearing was requested. A Stipulation of Findings and a Consent Agreement were
subsequently submitted by the parties to the Commission for consideration. The Stipulated
Findings are set forth as the Findings in this Order. The Consent Agreement has been approved.
I. ALLEGATIONS:
That Matthew Hutcheson, a public official/public employee in his capacity as the
Superintendent of the Jeannette City School District ("District"), Westmoreland County, violated
Sections 1103(a), 1104(a), 1105(b)(1), 1105(b)(4), 1105(b)(7), and 1105(b)(8) of the State Ethics
Act (Act 93 of 1998):
(1) When he realized a pecuniary benefit for himself and/or a member of his immediate
family by soliciting and/or accepting something of value, namely travel, hospitality
and/or lodging, from the MIND Research Institute, at a time when he was
advocating/recommending the use and purchase of the ST Math Program from
MIND Research Institute by the District;
Hutcheson, 19-033
Page 2
(2) When he utilized the authority of his public position for the private pecuniary
benefit of a member of his immediate family when he made a recommendation/final
recommendation to the Board of the District to hire his spouse as a Special
Education Classroom Assistant;
(3) When he utilized a District procurement card to make non -District related/non-
authorized purchases of a personal nature;
(4) When he failed to report his receipt of transportation, lodging, and hospitality from
MIND Research Institute upon a Statement of Financial interests filed for the 2017
calendar year; and
(5) When he filed deficient Statements of Financial Interests when he failed to identify
the interest rate of a reportable creditor for calendar years 2016 and 2017, failed to
identify his public office/position and the correct filing calendar year for calendar
year 2017, and failed to report his employment with Drivers On Call and/or Jim
Shorkey Auto Group for calendar year 2018.
II. FINDINGS:
Matthew J. Hutcheson ("Hutcheson") served as the Superintendent of the Jeannette City
School District ("District"), Westmoreland County, Pennsylvania, from. January 9, 2012,
until March 30, 2018.
a. Hutcheson was appointed as the Superintendent at a regular meeting of the
Jeannette City School District School Board ("Board") held on November 7, 2011.
b. Hutcheson was subsequently reappointed as the Superintendent during the January
18, 2016, meeting of the Board.
Hutcheson's contract had an effective term of five years beginning on July
1, 2016 and ending December 31, 2021.
2. Hutcheson resigned as the Superintendent effective March 30, 2018.
aa. Hutcheson submitted a letter dated September 7, 2017, to the Board,
stating his intent to retire on or before April 3, 2018.
bb. At its September 18, 2017, meeting, the Board accepted
Hutcheson's intent to retire on or before April 3, 2018.
C. Cynthia Hutcheson is the wife and an immediate family member of Hutcheson.
Cynthia Hutcheson received a degree in teaching from Westminster
College.
Hutcheson, 19-033
Page 3
2. She also maintains a degree in library science from Mansfield University.
3. Cynthia Hutcheson also received an English Second Language (ESL)
certificate through the District's Intermediate Unit.
2. The District is a third-class school district governed by a nine -Member Board.
3. At all relevant times, the Board held one legislative meeting on the third Monday of the
month.
a. Special meetings are held as necessary.
4. Voting at Board meetings occurs by either a roll call vote or a group voice vote.
a. Roll call voting is employed for matters such as personnel, expenditure of District
funds, budget, curriculum, etc.
b. A group voice vote is held for items such as approval of employee travel, monthly
bill list, and meeting adjournment.
C. Any abstention from a vote is specifically documented within the minutes.
d. Minutes of the District monthly meetings are approved by the Board at a subsequent
meeting of the Board for accuracy.
5. Board Members receive a meeting packet which includes the meeting agenda and
supportive information the Friday before a meeting, either via Board Does or by paper
copy.
a. The Board meeting agenda is prepared by the Superintendent and assembled for
distribution by the Board Secretary.
1. Since September 2016 the Board has used Board Does to create the agenda
for the Board meetings.
b. In addition to the upcoming meeting agenda, the meeting packet includes items
such as the minutes from the prior month's meeting, bill list, and requests for
professional development/workshops.
C. A Board Member can request an addition to the meeting agenda, through the
Superintendent.
6. Prior to a Board meeting, District Business Manager Paul Sroka prepares a list of all the
bills paid ("list of payments") from the last Board monthly meeting until the current
monthly meeting.
Hutcheson, 19-033
Page 4
a. This "list of payments" is provided to the Board Members during the monthly
meeting.
1. The Board Members vote to ratify the list of payments at the voting meeting
when they approve the financial reports.
b. Bills received from the Monday before the work session meeting until the day of
the voting meeting are called the "bills to be approved."
C. Once these bills are entered into the accounting system, they are given to the Board
Secretary to add to Board Does as "invoices payable" under the Financial Reports
section.
1. When the Board approved the "invoices payable," Sroka would then draft a
District check as payment.
2. The Board President, Vice President, and Treasurer have signature authority
over the District's bank account(s).
3. All three authorized signatories are required for each District check.
7. Through separate motion and vote at each monthly meeting, the Board will approve
acceptance of the Financial Report and payment of any invoices.
a. The Financial Report routinely addresses multiple items such as a listing of
payments from the general fund, capital, and cafeteria, invoices payable list,
expenditure accounts, P-card statements, etc.
1. The motion and vote regarding approval of all aspects of the Financial
Report occur with one all -encompassing vote.
b. Payments to vendors are held for distribution until the list of bills is approved at the
meeting with the exception of normal recurring bills such as utilities.
8. The District maintains and utilizes a policy manual in relation to the day-to-day operations
of the District.
a. The policies and local Board procedures adopted by the Board are intended to
establish the general and overall rules within which the day -today operations of
the District are to be governed.
1. The District Policy Manual is a public record and is available through the
District's website (www.jeannetteschooldistrict. or — District/School
Board/Board Docs/Policies).
Hutcheson, 19-033
Page 5
2. All District employees have access to the District Policy Manual through
the District website.
b. As the Superintendent, Hutcheson was subject to policies and procedures included
within the District Policy Manual.
C. Hutcheson affirmed being subject to the District Policy Manual via signing and
dating his Superintendent Agreement with the District on January 9, 2012.
9. Attendance at conferences and/or professional development programs for District staff
must be approved by the Board.
a. If a teacher or administrator, including the Superintendent, wants to attend a
conference/professional development program, a completed Request to Attend a
Professional Conference/Professional Development form must be submitted,
identifying the following:
1. The name of the conference/professional development program;
2. Date(s) of absence from the District;
3. Location of the conference;
4. The funding sources;
5. The estimated cost of the conference and travel;
6. The District building where the requestor worked;
7. The grades the requestor taught;
8. If a substitute was needed; and
9. The curricula addressed.
b. The completed request form is approved and signed by the Principal or the
requestor's immediate supervisor, the Director of Federal Programs/Student
Services (if those funds were used), then by the Superintendent, and lastly by the
Board at the Board meeting signifying approval.
1. The Board votes on "Teacher Professional Development Conferences and
Requests to Attend Professional Meetings" under the Personnel section of
the Board meeting agenda.
Hutcheson, 19-033
Page 6
2. The requests are identified in the minutes showing such information as the
employee's name, conference/location, costs, and dates which are included
in the agenda itself or as a spreadsheet attached to the agenda.
3. The Board approves the travel requests as one item, there is no approval of
each individual request.
10. Each year at the June meeting of the Board, a vote is taken to approve a list of annual
conferences that District representatives may attend.
a. The list has included such conferences as the Pennsylvania School Boards
Association Conference (PSBA), Business Officials Annual Conference (PASBO),
Pennsylvania Educational Technology Expo/Conference (PETE&C), and
International Society for Technology in Education (ISTE).
b. Although preauthorized by the Board, District employees or Board Members
wishing to attend one of the preapproved conferences were still required to
complete a Request to Attend a Professional Conference/Professional Development
form and have it approved prior to attendance.
11. During his period of employment with the District, Hutcheson did not submit requests for
Board consideration or approval to attend conferences or professional development
trainings.
12. MIND Research Institute ("MIND") is a California -based, nonprofit entity which was
founded in 1998.
a. MIND reports that it was created "with the innovative idea to teach math the way
children learn — through visuals and experiences."
b. MIND accomplishes this goal through development of visually based software
games, leading to the creation of "Spatial -Temporal (ST) Math."
13. Between June 26 and June 29, 2016, Hutcheson attended the 2016 ISTE conference in
Denver, Colorado.
a. Later during the evening of June 27, Hutcheson, Hutcheson's spouse, and the
District's Director of Federal Programs/Student Services, Stuart Albaugh, attended
an evening reception sponsored by MIND.
14. On January 4, 2017, at 11:20 a.m., at or about the time the District was installing the ST
Math program on the District's computer system, Brian Gresser ("Gresser") sent an email
to Hutcheson with the subject line "You're invited — Visual Math Summit: Equipping a
Generation of Math Superheroes."
a. The email invited Hutcheson and a District guest to attend the MIND event to be
held from January 25-27, 2017, in Irvine, California.
Hutcheson, 19-033
Page 7
b. The email further stated: "Accommodations at Hotel Irvine and airfare will be
covered by the host organization."
In order to attend the event, travel arrangements were to be made through MIND's
travel agency, Travelstore, and the email directed Hutcheson to contact "Fritzie" at
[email address redacted] to book between December 27 and January 20.
15. Hutcheson emailed Fritzie on January 6, 2017, 10:49 a.m., advising he was interested in
attending the Institute and asking for assistance with arranging the hotel and flights.
a. In his email to Fritzie, Hutcheson informed that he will be attending with his wife,
a certified librarian and ESL instructor currently working as a classroom assistant
providing remediation services to students on a daily basis.
b. Fritzic forwarded the email to Joan Frame ("Frame"), a Travelstore employee, to
make the arrangements.
16. On January 9, 2017, at 12:28 p.m., Frame emailed Hutcheson flight arrangements for him
and his wife Cynthia to attend the MIND Research Institute Visual Math Summit.
a. The arrangements confirmed a flight from Pittsburgh to Santa Ana, California, with
a layover in Chicago, departing on Wednesday, January 25, 2017, at 7:17 a.m.
b. The arrangements identified a return flight from Santa Ana, California to
Pittsburgh, with a layover in Denver, departing on Friday, January 27, 2017, at 1:33
P.M.
Wednesday, January 25, 2017, through Friday, January 27, 2017, were normal
business/school days at the District.
d. In a follow up email on January 9, 2017, at 1:00 p.m., Frame informed Hutcheson
that, per Brittany Braganza at MIND, MIND would not be paying for his wife's
airline ticket.
Hutcheson replied to Frame's email stating his wife is employed as an "ESL and
classroom assistant," and if MIND declines to pay for both he and his wife, they
are not interested in attending.
17. Following his receipt of the January 9, 2017, email from Frame, Hutcheson emailed
Gresser stating that his wife was denied participation in the conference by MIND, and as
such he will not be attending either.
a. In the email Hutcheson identified his wife as the ESL Coordinator for the District,
a classroom assistant, and that she holds a library certification.
b. Following his email to Gresser, Hutcheson advised Frame in a follow up email that
he spoke to Gresser, and that Gresser received approval through Brittney Braganza,
Hutcheson, 19-033
Page 8
Senior HR Assistant at MIND, to include Hutcheson's wife for the flights as
previously arranged.
18. Hutcheson and his wife departed on January 25, 2017, via United Airlines, to attend the
MIND Research Institute Visual Math Summit in Irvine, California.
a. The cost of each airline ticket was $644.60, for a total of $1,289.20.
b. MIND paid for both airline tickets.
19. Hutcheson and his wife stayed at the Hotel Irvine, Room #713, for the nights of
Wednesday, January 25, 2017, and Thursday, January 26, 2017, while attending the
conference.
a. The cost of the room was $159.50 per night, for a total cost of $319.58 which was
paid by MIND.
20. The agenda for the MIND Research Institute Visual Math Summit outlined a schedule of
activities beginning at 3:00 p.m. on the first day (January 25, 2017) and ending at 10:30
a.m. on the third day (January 27, 2017).
a. The first day's agenda included the event registration and an opening reception of
cocktails and heavy hors d'oeuvres.
b. The second day's agenda included event registration, various presentations and
breakout sessions from 9:00 a.m. to 4:20 p.m., and a 75-minute break for lunch.
1. The description for one breakout session stated: "Realize the power and
necessity of mathematical creativity and taste some wine."
2. The attendees had free time from 4:30 p.m. to 6:00 p.m.
3. From 6:00 p.m. to 9:30 p.m. a dinner prepared by a collection of notable
chefs demonstrating mathematics in culinary arts was provided.
C. The third and final day of the event started with breakfast from 8:00 a.m. to 9:00
a.m. followed by an expert panel and closing remarks from 9:00 a.m. to 10:30 a.m.
d. The MIND Research Institute Visual Math Summit consisted of approximately 7.5
hours of breakout sessions and speakers over a three-day period.
1. The majority of the summit consisted of meals, cocktails, and social events.
2. The summit was primarily a marketing tool used by MIND to market its
products to prospective and current users.
Hutcheson, 19-033
Page 9
21. Airfare for both Hutcheson and his wife to fly from Pittsburgh to the MIND event totaled
$1,289.20 ($644.60 each).
22. Hotel stay for two nights (January 25 and 26, 2017) at Hotel Irvine while Hutcheson and
his wife attended the MIND event totaled $319.58.
23. Hutcheson failed to disclose his receipt of travel, lodging and hospitality from MIND upon
his 2017 calendar year Statement of Financial Interests,
THE FOLLOWING FINDINGS RELATE TO HUTCHESON UTILIZING THE
DISTRICT PROCUREMENT CARD TO PAY FOR PERSONAL EXPENSES.
24. The District utilized procurement cards ("P-cards"), or credit cards, for making certain
District -related purchases,
a. BMO Harris Bank ("BMO") is the servicing agent of the District's P-cards.
1. BMO issued a monthly statement to the cardholder showing the activity on
the account for the month.
b. Each month BMO automatically withdrew funds from the District's Pennsylvania
Local Government Investment Trust ("PLGIT") account to pay the outstanding P-
card charges.
25. At all times during Hutcheson's tenure, the District provided various individuals with P-
cards to use.
a. At a minimum, P-cards were issued to all Board Members, Hutcheson, and the
Director of Federal Programs/Student Services, Stuart Albaugh ("Albaugh")
1. One P-card was maintained in the District Business Office.
2. Hutcheson was issued a P-card ending in 45544.
b. P-cards were to be used for only District -related purchases/expenses.
26. When a District employee or Board Member makes a purchase with a District P-card, a "P-
Card Expense Receipt Sheet" must be completed and submitted to the District Business
Office.
a. The P-Card Expense Receipt Sheet consists of columns for the user to complete,
including:
• the date of the charges
• a description of the charges
• location of the charge
Hutcheson, 19-033
Page 10
the program
whether a receipt is attached
if no receipt is attached, the reason why and the expense amount.
b. When the District Business Office receives the completed and signed form, the
applicable budget account numbers are placed/assigned to the form.
The expense receipt sheet has signature space for the Assistant Business Manager,
Business Manager, and Superintendent to sign.
d. If an employee utilizes the employee's P-card for a personal expense, the employee
must reimburse the District.
27. District Policy Section 300 "Administrative Employees" Sub -Section 331 Job Related
Expenses, states in part:
a. "[P]ayment of the actual and necessary expenses, including travel expenses, of any
district administrator that are incurred in the course of performing services for the
district shall be reimbursed in accordance with Board policy."
1. The validity of payments for job -related expenses shall be determined by
the Superintendent.
2. Actual and necessary expenses incident to attendance at functions out of the
District shall be reimbursed to an administrator if approval has been
obtained in advance from the Board.
b. As the Superintendent, Hutcheson was a District employee.
As a District employee Hutcheson was required to obtain the approval of
the Board President for his District-related/professional development travel.
28. The International Society for Technology in Education ("ISTE") is a nonprofit organization
with the stated goal of "[working] with the global education community to accelerate the
use of technology and to inspire innovation."
a. The main headquarters of ISTE is located at 621 SW Morrison Street, Suite 800,
Portland, OR 97205.
29. ISTE holds an annual Conference and Exposition ("Conference") in different cities, at
which various individuals speak and companies present and demonstrate their products.
a. In 2016, ISTE held the Conference in Denver, Colorado between Sunday, June 26
and Wednesday, June 29.
Hutcheson, 19-033
Page I I
30. At the June 22, 2015, Board meeting, the Board approved the 2015-2016 Conference
Attendance listing, which included the 2016 ISTE Conference.
a. Prior to any District -related travel, the Board must approve all requests.
1. At the December 7, 2015, Board meeting, the Board approved Albaugh's
request to attend the 2016 ISTE Conference in Denver, Colorado.
2. Albaugh's request to attend the 2016 ISTE Conference in Denver, Colorado
from June 26-29, 2016, was on file at the District.
3. Albaugh was the Director of Federal Programs/Student Services at the
District.
4. No approval was requested by, or given to, Hutcheson.
b. Minutes of the Board meeting do not record the Board approving a request for any
other District employee to attend the 2016 ISTE Conference.
1. A review of the District Request to Attend forms did not identify any
Request to Attend forms to attend the ISTE Conference in Denver, Colorado
submitted by Hutcheson or Cynthia Hutcheson.
C. Two District Board Members were present at the 2016 ISTE Conference and were
aware that Hutcheson, his wife, and other non-preauthorized District employees
were in attendance.
1. Neither the Board Members in attendance nor the Board as a whole, took
any action regarding the non -approved District employee travel.
2. The District Board Members were unaware that Cynthia Hutcheson's
registration was paid by the District.
31. ISTE registrations for the 2016 ISTE Conference included registrations for six. District
attendees, including Hutcheson and his wife.
a. Although Albaugh was the only District representative authorized by the Board to
attend the 2016 ISTE Conference in Denver, Colorado, a total of six District
representatives, including Hutcheson and his wife, were registered to attend, as
shown below:
Attendee
District Position
Registration
No.
Price
Payment
Date
Method of
Payment
Albaugh Stuart
Director of Federal
Program s- Student Svcs
14100162
$434
11/13/2015
M/C 5551
Vuksan Suzanne
Elementary Teacher
14100455
$434
11/20/2015
M/C 5544
Hutcheson Cynthia
Classroom Assistant
14180396
$534
1 06/20/2016
M/C 5544
Hutcheson, 19-033
Page 12
Hutcheson Matthew
Superintendent
14100106
$434
11/12/2015
M/C 5544
Vaierio David
Board Member
14105528
$434
05/13/2016
Ck #35843
Yorio Joseph
Board Member
14105535
$434
05/13/2016
Ck #35843
b. Cynthia Hutcheson's and Suzanne Vuksan's registration fees were paid with
Hutcheson's District P-card ending in #5544.
1. The cost of Cynthia Hutcheson's registration fee was $100 higher than the
individual registration fees for the other District representatives attending
the 2016 ISTE Conference.
2. Cynthia Hutcheson's registration fee was higher because of the late date of
her registration.
C. Board Members do not require specific/individual approval/authorization to attend
a District -related conference.
d. Registered attendees could attend the workshops, sessions, and lectures at the 2016
ISTE Conference, as well as visit the vendor booths set up throughout the space.
32. Using a personal MasterCard credit card, Hutcheson purchased airline tickets for himself
and his wife to travel to the 2016 ISTE Conference via American Airlines.
a. The American Airlines receipt identifies the flight as originating from Pittsburgh to
Denver, with a layover in Charlotte, departing June 25, 2016, at 7:10 p.m.
b. The American Airlines receipt identifies the return flight departing from Denver to
Pittsburgh, with a layover in Charlotte, leaving July 2, 2016, at 1 I :26 p.m.
The cost of each ticket was $440.20.
33. Hutcheson prepared and submitted to the District Business Office a Jeannette City School
District Mileage/Expense Reimbursement Form for December -January 2015-2016,
stamped received February 1, 2016, which included the cost of the airfare to the 2016 ISTE
Conference in the amount of $440.20.
a. Attached to the Reimbursement Form was an American Airlines receipt dated
February 1, 2016, identifying the purchase of roundtrip tickets for Matthew
Hutcheson and Cynthia Hutcheson at a cost of $440.20 per ticket.
b. Hutcheson paid for the American Airlines' tickets with his MasterCard.
1. Hutcheson did not request reimbursement from the District for the cost of
his wife's flight to Denver for the 2016 ISTE Conference.
C. Hutcheson was reimbursed $626.64 by the District for his airfare to the 2016 ISTE
Conference, as well as other items unrelated to the 2016 ISTE Conference,
Hutcheson, 19-033
Page 13
identified on his Mileage/Expense Reimbursement Form submitted for December -
January 2015-2016.
34. Using the District P-card, Hutcheson secured and paid for lodging at the Crowne Plaza
Hotel, 1450 Glenarm Place, Denver, CO, for himself and his wife for the 2016 ISTE
Conference.
a. Crowne Plaza Hotel Folio #604935 is associated with Hutcheson's stay.
1. The check -in date was June 25, 2016, and the checkout date was June 30,
2016.
b. The 2016 ISTE Conference ended on Wednesday, June 29, 2016.
Hutcheson and his wife checked out of the hotel on Thursday, June 30,
2016.
35. Following his attendance at the 2016 ISTE Conference, Hutcheson prepared and submitted
a P-Card Expense Receipt Sheet to the District Business Office for May/June 2016
(undated).
a. Included on the P-Card Expense Receipt Sheet was a charge incurred on June 9,
2016, for $274,25 at the Crowne Plaza Hotel, Denver, Colorado.
1. The charge was a deposit for the hotel stay for the 2016 ISTE Conference
in Denver, Colorado.
b. Also included on the P-Card Expense Receipt Sheet was a charge incurred on June
20, 2016, for $534.00 identified as "ISTE Conference."
1. Attached to the P-Card Expense Receipt Sheet was an email receipt from
iste@iste.Qrg to Cynthia Hutcheson regarding her registration confirmation
and stating that the credit card has been charged $534.00.
36. Approximately one month after he submitted his May/June P-Card Expense Receipt Sheet,
Hutcheson submitted a P-Card Expense Receipt Sheet for July 2016 (undated).
a. On the P-Card Expense Receipt Sheet Hutcheson identified seven of the nine
charges made to his P-card as being related to the "Denver Conference" (2016 ISTE
Conference) as follows:
If No
Budget
Receipt
Receipt,
Expense
Account
Date
Description, Location, etc.
Program
Attached YIN
Why
Amount
No.
6/28/2016
SQ ISTE
Denver Conference
Y
$19.33
6/29/2016
Salt rass
Denver Conference
1 'Y
$SS.00
Hutcheson, 19-033
Page 14
7/3/2016
Pitts Airport Parking
Denver Conference
Y
$64.00
7/1/2016
Springhill Suites Denver
Denver Conference
Y
$1,428.65
Vuksan
6/30/2016
CP Hotels Denver
Denver Conference
Y
$1,232.00
6/30/2016
Holiday Inns Golden
Denver Conference
PAID BY DR.
HUTCH
$154.80
7/2/2016
Advantage Car
Denver Conference
Y
$474.39
7/8/2016
Southside Works Garage
N
$8.00
7/25/2016
Dunkin Donuts
Y
$24.88
$3,461.05
b. Included on the P-Card Expense Receipt Sheet was a charge of $154.80 on June
30, 2016, for Holiday Inns Golden Program Denver Conference.
1. Handwritten beside the Holiday Inns Golden charge was a note "PAID BY
DR. HUTCH."
37. Using his District P-card, Hutcheson secured lodging at the Holiday Inn Express & Suites,
17140 West Colfax Avenue, Golden, CO 80401, Folio #8779 for himself and his wife.
a. Holiday Inn Express & Suites Folio ##8779 identifies a check -in date of June 30,
2016, and a checkout date of July 2, 2016.
b. Hutcheson utilized his District P-card to pay ($154.80) for the first night (June 30,
2016) of his stay.
District Assistant Business Manager, Julie Lea, reviewed District deposits and
records but found no evidence of a reimbursement of the $154.80 to the District.
d. Hutcheson utilized a personal Visa credit card to pay for the second night (July 1,
2016) of his stay.
The charge to Hutcheson's personal Visa credit card for the second night's
stay was $203.95.
38. Also included on the P-Card Expense Receipt Sheet was a charge incurred on July 2, 2016,
for Advantage Rent a Car ("Advantage") in the amount of $474.39, identified as part of
the "Program Denver Conference."
a. Upon arriving at Denver International Airport on Saturday, June 25, 2016,
Hutcheson rented a Hyundai Accent (Vehicle #ECGU013099 License Plate
#CQ0231) from Advantage at the airport (9:08 p.m.)
Hutcheson rented the Hyundai Accent for one week starting Saturday, June
25 through Saturday, July 2, 2016.
2. Hutcheson did not utilize any hotel shuttle service to/from the airport/hotel.
Hutcheson, 19-033
Page 15
3. All necessary amenities for the 2016 ISTE Conference (conference center,
restaurants, etc.) were within walking distance of the Crowne Plaza Hotel
where Hutcheson and his wife were staying during the Conference.
b. From Thursday, June 30 to Saturday, July 2, 2016, Hutcheson and his wife utilized
the rental vehicle to drive from Denver, Colorado to Golden, Colorado for a
personal vacation.
Hutcheson and his wife returned the rental vehicle to Advantage on July 2,
2016, at 11:27 a.m.
39. Hutcheson's receipt from Advantage documented the vehicle odometer reading leaving the
rental agency (9,289) and the odometer reading returning to the rental agency (9,829) for
a total of 540 miles driven.
a. Mileage from Advantage Rent A Car, Denver International Airport, 23790 E 78"'
Avenue, Denver, CO 80249 to the Crowne Plaza Hotel, 1450 Glenarm Place,
Denver, Colorado 80202 and back is approximately 46 miles.
b. Hutcheson and his spouse incurred approximately 494 personal miles on the
Advantage car rental.
Mileage when car returned 540
Mileage airport to Crowne Plaza 23
Mileage Crowne Plaza to airport 23
Total Personal Miles 494
40. Hutcheson realized a pecuniary gain of $474.39 when in Colorado he charged the cost of
an Advantage rental car to his District P-card which he then used as transportation for he
and his wife to travel to Golden, Colorado for personal purposes.
41. Hutcheson realized a pecuniary gain of no less than $1,008.39, when he utilized his District
P-Card to pay for personal expenses in relation to his attendance at the 2016 ISTE
Conference in Denver, Colorado, and extended stay in Colorado.
a. Hutcheson realized a pecuniary gain of $534.00 when he charged his wife's
registration for the 2016 ISTE Conference in Denver to his District P-card, when
she was not authorized to attend nor was eligible to attend as a District employee.
1. Cynthia Hutcheson was not eligible to attend as a District employee due to
her position as a Classroom Assistant.
2. Cynthia Hutcheson's term of employment with the District ended on June
10" for 2016.
3. Attendance by Cynthia Hutcheson at District expense enabled her to receive
credit toward maintaining her Pennsylvania Teaching Certificate.
Hutcheson, 19-033
Page 16
b. Hutcheson realized a pecuniary gain of $474.39 when he charged the costs of the
Advantage rental car which he and his wife used for personal travel after the 2016
ISTE Conference in Denver, Colorado.
THE FOLLOWING FINDINGS RELATE TO HUTCHESON'S FAILURE TO REPORT
TRAVEL, LODGING AND HOSPITALITY RECEIVED FROM MIND RESEARCH
INSTITUTE ON HIS CALENDAR YEAR 2017 STATEMENT OF FINANCIAL
INTERESTS AND HIS FAILURE TO IDENTIFY THE INTEREST RATE OF A
REPORTABLE CREDITOR FOR CALENDAR YEARS 2016 AND 2017, IDENTIFY HIS
PUBLIC OFFICEIPOSITION AND FILING YEAR FOR CALENDAR YEAR 2018, AND
REPORT HIS EMPLOYMENT WITH JIM SHORKEY AND DRIVERS ON CALL FOR
CALENDAR YEAR 2018.
42. Statement of Financial Interests ("SFI") forms are required to be annually filed by public
employees.
a. SFI forms are required to be filed by no later than May I" of each year that a public
employee holds public employment.
b. SFI forms require filers to disclose financial information pertaining to the preceding
calendar year.
1. For each calendar year he served as the Superintendent of the District,
Hutcheson was required to file his SFI by May 1st of the following calendar
year.
43. Information to be disclosed on SFIs filed by public officials and public employees is
mandated by 65 Pa.C.S. § 1105.
a. Sections 1105(b)(1) through 1105(b)(10) identify specific information to be
disclosed as well as exceptions to disclosure requirements when applicable.
1. Section 1105(b)(1) directs the disclosure on SFIs of the "Name, address and
public position."
2. Section 1105(b)(4) directs the disclosure on SFIs of "The name and address
of each creditor to who is owed in excess of $6,500 and the interest rate
thereon."
3. Section 1105(b)(5) directs the disclosure on SFIs of "The name and address
of any direct or indirect source of income totaling in aggregate $1,300 or
more."
4. Section 1 I05(b)(7) directs the disclosure on SFIs of "The name and address
of the source and the amount of any payment for or reimbursement of actual
expenses for transportation and lodging or hospitality received in
Hutcheson, 19-033
Page 17
connection with public office or employment where such actual expenses
for transportation and lodging or hospitality exceed $650 in an aggregate
amount per year."
44. On October 15, 2019, an SFI compliance review was completed for the District.
a. The District was only able to locate Slats for calendar years 2016, 2017, and 2018.
b. SFIs from earlier years were completed and submitted to a former Superintendent's
secretary.
45. Hutcheson's SFIs for calendar years 2016, 2017, and 2018 were identified as being filed
as follows:
Calendar Year
Date Filed
2016
April 13, 2017
2017
February 13, 2018
2018
February 18, 2019
46. Hutcheson failed to identify the interest rate of a reportable creditor for calendar years 2016
and 2017 (Box 09).
a. Hutcheson's calendar year 2018 SFI included the interest rate of a reportable
creditor.
47. Hutcheson failed to identify his public office/position hold/held for calendar year 2017
(Box 04).
a. Hutcheson's calendar year 2016 SFI showed "hold" for his position as
Superintendent of the District.
b. Hutcheson's calendar year 2018 SFI showed "held" for his position as
Superintendent of the District.
48. Hutcheson failed to identify the filing calendar year for calendar year 2017 (Box 07).
a. Hutcheson's calendar year 2016 and 2018 SFIs showed the filing calendar year.
49. Hutcheson failed to report his receipt of transportation, lodging, and hospitality from
MIND in calendar year 2017 (Box 12).
a. Hutcheson received travel/lodging/hospitality valued at $964.18 from MIND
during calendar year 2017.
50. Hutcheson failed to report all office, directorship or employment on his SFI form for
calendar year 2018 (Box 13).
Hutcheson, 19-033
Page 18
a. During calendar year 2018, Hutcheson was employed by both Jim Shorkey Auto
Group and Drivers On Call.
III. DISCUSSION:
As the Superintendent of the Jeannette City School District ("District"), Westmoreland
County, Pennsylvania, from January 9, 2012, until March 30, 2018, Respondent Matthew
Hutcheson, also referred to herein as "Respondent," "Respondent Hutcheson," and "Hutcheson,"
was a public official/public employee subject to the provisions of the Public Official and Employee
Ethics Act ("Ethics Act"), 65 Pa. C.S. § 1101 et seq.
The allegations are that Hutcheson violated Sections 1103(a), 1104(a), 1105(b)(1),
1105(b)(4), 1105(b)(7), and 1105(b)(8) of the Ethics Act:
(1) When he realized a pecuniary benefit for himself and/or a member of his immediate
family by soliciting and/or accepting something of value, namely travel, hospitality
and/or lodging, from MIND Research Institute, at a time when he was
advocating/recommending the use and purchase of the ST Math Program from
MIND Research Institute by the District;
(2) When he utilized the authority of his public position for the private pecuniary
benefit of a member of his immediate family when he made a recommendation/final
recommendation to the School Board of the District to hire his spouse as a Special
Education Classroom Assistant;
(3) When he utilized a District procurement card to make non -District related/non-
authorized purchases of a personal nature;
(4) When he failed to report his receipt of transportation, lodging, and hospitality from
MIND Research Institute upon a Statement of Financial Interests ("SFI") filed for
the 2017 calendar year; and
(5) When he filed deficient SFIs when he failed to identify the interest rate of a
reportable creditor for calendar years 2016 and 2017, failed to identify his public
office/position and the correct filing calendar year for calendar year 2017, and
failed to report his employment with Drivers On Call and/or Jim Shorkey Auto
Group for calendar year 2018.
Per the Consent Agreement of the parties, the Investigative Division has exercised its
prosecutorial discretion to nolle pros the first and second allegations set forth above as well as the
alleged violation of Section 1104(a) of the Ethics Act. We therefore need not address those
allegations.
Pursuant to Section 1103(a) of the Ethics Act, a public official/public employee is
prohibited from engaging in conduct that constitutes a conflict of interest:
Hutcheson, 19-033
Page 19
§ 1103. Restricted activities
(a) Conflict of interest. —No public official or public
employee shall engage in conduct that constitutes a conflict of
interest.
65 Pa.C.S. § 1103(a).
The term "conflict of interest" is defined in the Ethics Act as follows:
§ 1102. Definitions
"Conflict" or "conflict of interest." Use by a public
official or public employee of the authority of his office or
employment or any confidential information received through his
holding public office or employment for the private pecuniary
benefit of himself, a member of his immediate family or a business
with which he or a member of his immediate family is associated.
The term does not include an action having a de minimis economic
impact or which affects to the same degree a class consisting of the
general public or a subclass consisting of an industry, occupation or
other group which includes the public official or public employee, a
member of his immediate family or a business with which he or a
member of his immediate family is associated.
65 Pa.C.S. § 1102.
Subject to the statutory exclusions to the Ethics Act's definition of the term "conflict" or
"conflict of interest," 65 Pa.C.S. § 1102, pursuant to Section 1103(a) of the Ethics Act, a public
official/public employee is prohibited from using the authority of public office/employment or
confidential information received by holding such a public position for the private pecuniary
benefit of the public official/public employee himself, any member of his immediate family, or a
business with which he or a member of his immediate family is associated.
Section 1105(b) of the Ethics Act and its subsections detail the financial disclosure that a
person required to file the SFI form must provide.
Section 1105(b)(1) of the Ethics Act requires the filer to disclose on the SFI his name,
address, and public position.
Subject to certain statutory exceptions, Section 1105(b)(4) of the Ethics Act requires the
filer to disclose on the SFI the name and address of each creditor to whom is owed in excess of
$6,500 and the interest rate thereon.
Subject to certain statutory exceptions, Section 1105(b)(7) of the Ethics Act requires the
filer to disclose on the SFI the name and address of the source and the amount of any payment for
or reimbursement of actual expenses for transportation and lodging or hospitality received in
Hutcheson, 19-033
Page 20
connection with public office or employment where such actual expenses exceed $650 in an
aggregate amount per year.
Section 1105(b)(8) of the Ethics Act requires the filer to disclose on the SFI any office,
directorship or employment in any business entity.
As noted above, the parties have submitted a Consent Agreement and Stipulation of
Findings. The parties' Stipulated Findings are set forth above as the Findings of this Commission.
We shall now summarize the relevant facts as contained therein.
Hutcheson began serving as the Superintendent of the District on January 9, 2012.
Hutcheson resigned from his position as the Superintendent of the District effective March 30,
2018. Cynthia Hutcheson is Hutcheson's wife. At all times relevant to this matter, Cynthia
Hutcheson was employed with the District as a Classroom Assistant.
The District utilized procurement cards ("P-cards") that were to be used only for making
certain District -related purchases. Each month the bank that was the servicing agent for the
District's P-cards automatically withdrew funds from the District's Pennsylvania Local
Government Investment Trust account to pay the outstanding R-card charges. During Hutcheson's
employment with the District, he was issued a P-card.
The International Society for Technology in Education ("ISTE") is a nonprofit organization
with the stated goal of "[working] with the global education community to accelerate the use of
technology and to inspire innovation." ISTE holds an annual Conference and Exposition
("Conference") in different cities. In 2016, ISTE held the Conference in Denver, Colorado, from
Sunday, June 26 through Wednesday, June 29. At a meeting held on June 22, 2015, the District
School Board (`Board") approved the 2016 ISTE Conference as a conference that could be
attended by Board Members and District teachers and administrators. Cynthia Hutcheson was not
eligible to attend the 2016 ISTE Conference as a District employee because she was not employed
as a District teacher or administrator.
On June 25, 2016, Hutcheson and his wife flew to Denver, Colorado, to attend the 2016
ISTE Conference. Upon arriving at Denver International Airport, Hutcheson used the District P-
card to rent a car from Advantage Rent a Car ("Advantage"). Hutcheson and his wife stayed at
the Crowne Plaza Hotel in Denver, Colorado, while they attended the Conference. Hutcheson
used his District P-card to pay for his wife's Conference registration fee of $534.00. The 2016
ISTE Conference ended on June 29, 2016, and Hutcheson and his wife checked out of their hotel
on June 30, 2016.
After Hutcheson and his wife checked out of their hotel, they used their rental car to drive
to Golden, Colorado, for a vacation. Hutcheson and his wife stayed at the Holiday Inn Express &
Suites in Golden, Colorado, from June 30 to July 2, 2016. Hutcheson and his wife returned the
rental car to Advantage on July 2, 2016. Hutcheson and his wife used the rental car to drive
approximately 494 miles for personal purposes. On July 2, 2016, Hutcheson charged the amount
of $474.39 to the District P-card to pay Advantage for the use of the rental car.
Hutcheson, 19-033
Page 21
Following his attendance at the 2016 ISTE Conference, Hutcheson submitted P-Card
Expense Receipt Sheets to the District Business Office for May/June 2016 and July 2016. The P-
Card Expense Receipt Sheets included charges of $534.00 for Cynthia Hutcheson's registration
for the 2016 ISTE Conference and $474.39 for the cost of renting the car from Advantage. The
parties have stipulated that Hutcheson realized a pecuniary gain of no less than $1,008.39 when he
utilized his District P-card to pay his wife's registration fee of $534.00 for the 2016 ISTE
Conference when she was not authorized or eligible to attend the Conference as a District
employee and to pay $474.39 for the cost of a rental car that he and his wife used for personal
travel after the Conference.
While Hutcheson and his wife were at the 2016 ISTE Conference, they attended an evening
reception sponsored by MIND Research Institute, which is a California -based, nonprofit entity that
develops visually based software games to teach math to children. On January 4, 2017, Brian
Gresser of MIND sent an email to Hutcheson which invited him and a District guest to attend the
MIND Research Institute Visual Math Summit to be held from January 25, 2017, to January 27,
2017, in Irvine, California. The email stated that "accommodations at Hotel Irvine and airfare will
be covered by the host organization."
On January 25, 2017, Hutcheson and his wife departed via United Airlines from Pittsburgh,
Pennsylvania, to attend the MIND Research Institute Visual Math Summit in Irvine, California.
The cost of each airline ticket was $644.60. Hutcheson and his wife stayed at the Hotel Irvine for
two nights while attending the conference. The total cost of the room at the Hotel Irvine was
$319.58. MIND Research Institute paid for the airline tickets and the room at the Hotel Irvine.
As for Hutcheson's SFIs, Hutcheson failed to disclose his receipt of travel, lodging and
hospitality valued at $964.18 from MIND Research Institute on his SFI for calendar year 2017.
Hutcheson further failed to: (1) identify the interest rate on the amount owed to a reportable
creditor on his SFIs for calendar years 2016 and 2017; (2) identify his public office/position and
the filing calendar year on his SFI for calendar year 2017; and (3) report his employment with both
Jim Shorkey Auto Group and Drivers On Call on his SFI for calendar year 2018.
Having highlighted the Stipulated Findings and issues before us, we shall now apply the
Ethics Act to determine the proper disposition of this case.
The parties' Consent Agreement sets forth a proposed resolution of the allegations as
follows:
3. The Investigative Division will recommend the following in relation
to the above allegations:
a. That a violation of Section 1103(a) of the Public
Official and Employee Ethics Act, 65 Pa.C.S. §
1103(a), occurred in relation to Hutcheson's use of a
Jeanette City School District procurement card to
make non -District related purchases of a personal
Hutcheson, 19-033
Page 22
nature resulting in a private pecuniary benefit to
Hutcheson.
b. That a violation of Sections 1105(b)(1), (4), (7), and
(8) of the Public Official and Employee Ethics Act
occurred in relation to Hutcheson's failure to report
his receipt of transportation, lodging, and hospitality
from MIND Research Institute upon a Statement of
Financial Interests filed for the 2017 calendar year;
and when he failed to identify the interest rate of a
reportable creditor for calendar years 2016 and 2017;
when he failed to identify his public office/position
and the correct filing calendar year for calendar year
2017; and when he failed to report his employment
with Drives on Call and/or Jim Shorkey Auto Group
for calendar year 2018.
C. That the remaining allegations be nolle prossed.
4. Hutcheson agrees to make payment in the amount of $1,000.00 in
settlement of this matter payable to Jeannette City School District,
Westmoreland County, and forwarded to the Pennsylvania State
Ethics Commission, within thirty (30) days of the issuance of the
final adjudication in this matter.
5. In the event he has not already done so, Hutcheson agrees to file
complete and accurate amended Statements of Financial Interests
with the Jeannette City School District, Westmoreland County,
through the Pennsylvania State Ethics Commission, for calendar
years 2016, 2017 and 2018 within thirty (30) days of the issuance of
the final adjudication in this matter.
6. Hutcheson agrees to not accept any reimbursement, compensation
or other payment from the Jeannette City School District
representing a full or partial reimbursement of the amount paid in
settlement of this matter.
7. The Investigative Division will recommend that the State Ethics
Commission take no further action in this matter; and make no
specific recommendations to any law enforcement or other authority
to take action in this matter. Such, however, does not prohibit the
Commission from initiating appropriate enforcement actions in the
event of Respondent's failure to comply with this agreement or the
Commission's order or cooperating with any other authority who
may so choose to review this matter farther.
Hutcheson, 19-033
Page 23
Consent Agreement, at 2-3.
In considering the Consent Agreement, we agree with the patties that a violation of Section
1103(a) of the Ethics Act occurred in relation to Hutcheson's use of a District P-card to make non -
District related purchases of a personal nature, resulting in a private pecuniary benefit to himself.
As the Superintendent of the District, Hutcheson was issued a District P-card, which was
to be used only for making certain District -related purchases. Hutcheson used the authority of his
public position when he utilized his District P-card to pay for his wife's registration fee of $534.00
for attending the 2016 ISTE Conference even though she was not authorized or eligible to attend
the Conference as a District employee and to pay $474.39 for the cost of a rental car that he and his
wife used for personal travel after the Conference. The parties have stipulated that Hutcheson
realized a pecuniary gain of no less than $1,008,39 when he utilized his District P-card to pay for
his wife's Conference registration fee and the use of the rental car.
With each element of a violation of Section 1103(a) established, we hold that Hutcheson
violated Section 1103(a) of the Ethics Act, 65 Pa.C.S. § 1103(a), in relation to his use of a District
P-card to make non -District related purchases of a personal nature, resulting in a private pecuniary
benefit to himself.
We accept the recommendation of the parties, and we hold, that a violation of Sections
I105(b)(1), (4), (7), and (8) of the Ethics Act, 65 Pa.C.S. §§ 1105(b)(1), (4), (7), and (8), occurred
in relation to Hutcheson's failure to report his receipt of transportation, lodging, and hospitality
from MIND Research Institute on his SFI filed for the 2017 calendar year; when he failed to
identify the interest rate of a reportable creditor on his SFIs for calendar years 2016 and 2017;
when he failed to identify his public office/position and the correct filing calendar year on his SFI
for calendar year 2017; and when he failed to report his employment with Drives on Call and/or
Jim Shorkey Auto Group on his SFI for calendar year 2018.
As part of the Consent Agreement, Hutcheson has agreed to make payment in the amount
of $1,000.00 payable to Jeannette City School District, Westmoreland County, and forwarded to
this Commission within thirty (30) days of the issuance of the final adjudication in this matter.
Hutcheson has agreed to not accept any reimbursement, compensation or other payment from the
District representing a full or partial reimbursement of the amount paid in settlement of this matter.
To the extent he has not already done so, Hutcheson has agreed to file complete and accurate
amended SFIs with the District, through this Commission, for calendar years 2016, 2017, and 2018
within thirty (30) days of the issuance of the final adjudication in this matter.
We determine that the Consent Agreement submitted by the parties sets forth a proper
disposition for this case, based upon our review as reflected in the above analysis and the totality
of the facts and circumstances.
Accordingly, per the Consent Agreement of the parties, Hutcheson is directed to make
payment in the amount of $1,000.00 payable to Jeannette City School District, Westmoreland
County, and forwarded to this Commission by no later than the thirtieth (30") day after the mailing
date of this adjudication and Order.
Hutcheson, 19-033
Page 24
Per the Consent Agreement of the parties, Hutcheson is directed to not accept any
reimbursement, compensation or other payment from the District representing a full or partial
reimbursement of the amount paid in settlement of this matter.
To the extent he has not already done so, Hutcheson is directed to file complete and
accurate amended SFIs for calendar years 2016, 2017, and 2018 with the District, through this
Commission, by no later than the thirtieth (30"') day after the mailing date of this adjudication and
Order.
Compliance with the foregoing will result in the closing of this case with no further action
by this Commission. Noncompliance will result in the institution of an order enforcement action.
IV. CONCLUSIONS OF LAW:
1. As the Superintendent of the Jeannette City School District ("District"), Westmoreland
County, Pennsylvania, from January 9, 2012, until March 30, 2018, Respondent Matthew
Hutcheson ("Hutcheson") was a public official/public employee subject to the provisions
of the Public Official and Employee Ethics Act ("Ethics Act"), 65 Pa.C.S. § 1101 et seq.
2. Hutcheson violated Section 1103(a) of the Ethics Act, 65 Pa.C.S. § 1103(a), in relation to
his use of a District procurement card to make non -District related purchases of a personal
nature, resulting in a private pecuniary benefit to himself.
3. A violation of Sections 1105(b)(1), (4), (7), and (8) of the Ethics Act, 65 Pa.C.S. §§
1105(b)(1), (4),(7), and (8), occurred in relation to Hutcheson's failure to report his receipt
of transportation, lodging, and hospitality from MIND Research Institute on his Statement
of Financial Interests ("SFI") filed for the 2017 calendar year; when he failed to identify
the interest rate of a reportable creditor on his SFIs for calendar years 2016 and 2017; when
he failed to identify his public office/position and the correct filing calendar year on his
SFI for calendar year 2017; and when he failed to report his employment with Drives on
Call and/or Jim Shorkey Auto Group on his SFI for calendar year 2018.
In Re: Matthew Hutcheson, File Docket: 19-033
Respondent Date Decided: 3/29/21
Date Mailed: 4/1/21
ORDER NO. 1780
I. Matthew Hutcheson ("Hutcheson"), as the Superintendent of the Jeannette City School
District ("District"), Westmoreland County, Pennsylvania, violated Section 1 I03(a) of the
Public Official and Employee Ethics Act ("Ethics Act"), 65 Pa.C.S. § 1103(a), in relation
to his use of a District procurement card to make non -District related purchases of a
personal nature, resulting in a private pecuniary benefit to himself.
2. A violation of Sections 1105(b)(1), (4), (7), and (8) of the Ethics Act, 65 Pa.C.S. §§
I I05(b)(1), (4), (7), and (8), occurred in relation to Hutcheson's failure to report his receipt
of transportation, lodging, and hospitality from MIND Research Institute on his Statement
of Financial Interests ("SFI") filed for the 2017 calendar year; when he failed to identify
the interest rate of a reportable creditor on his SFIs for calendar years 2016 and 2017; when
he failed to identify his public office/position and the correct filing calendar year on his
SFI for calendar year 2017; and when he failed to report his employment with Drives on
Call and/or Jim Shorkey Auto Group on his SFI for calendar year 2018.
Per the Consent Agreement of the parties, Hutcheson is directed to make payment in the
amount of$1,000.00 payable to Jeannette City School District, Westmoreland County, and
forwarded to the Pennsylvania State Ethics Commission by no later than the thirtieth (301h)
day after the mailing date of this Order.
4. Per the Consent Agreement of the parties, Hutcheson is directed to not accept any
reimbursement, compensation or other payment from the District representing a full or
partial reimbursement of the amount paid in settlement of this matter.
5. To the extent he has not already done so, Hutcheson is directed to file complete and
accurate amended SFIs for calendar years 2016, 2017, and 2018 with the District, through
this Commission, by no later than the thirtieth (30th) day after the mailing date of this Order.
6. Compliance with paragraphs 3, 4, and 5 of this Order will result in the closing of this case
with no further action by this Commission.
a. Non-compliance will result in the institution of an order enforcement action.
Y THE COMMISSION,
Nicholas A. Cola ella, CFr